Throughout
2021,
the
risk
management
activity
was
carried
out
on
the
basis
of
the
Policies
and
Procedures
regarding
the
functioning of the company as an A.F.I.M. in terms of risk management.
The
risk
management
system
includes
a
set
of
analyses,
diversification
charts
of
the
financial
instruments
in
the
portfolio,
the
identification
and
assessment
of
financial
risks,
as
well
as
proposals
and
recommendations
to
mitigate
the
effects
of
the risks related to the Company's investment and general activity.
Throughout
2021,
Quarterly
Reports
were
prepared
on
the
significant
risks
to
which
the
company's
activity
is
exposed.
Within
Transilvania
Investments
,
the
financial
and
operational
risks
were
assessed,
monitored
and
treated
in
order
to
reduce
their
impact.
In
the
quarterly
reports,
a
number
of
recommendations
were
made
to
keep
the
company's
activity
in
line with the risk profile communicated to investors.
The
synthetic
diagram
of
the
exposures
registered
by
Transilvania
Investments
towards
various
financial
assets
and
activities,
according
to
the
F.S.A
Regulation
no.
15/2004
and
Law
no.
243/2019,
was
prepared
monthly.
Throughout
2021,
the level of holdings in various financial instruments was within the limits set forth by the legislation in force.
In
accordance
with
its
risk
management
policies
and
procedures,
Transilvania
Investments
performed
crisis
simulations
under
normal
and
exceptional
market
conditions,
which
would
allow
the
assessment
of
market
risk,
as
well
as
under
normal
and exceptional liquidity conditions, which would allow the assessment of liquidity risk.
In
crisis
simulations,
the
impact
of
stress
scenarios,
both
under
normal
and
exceptional
conditions,
was
estimated
on
each
financial
instrument
in
the
portfolio
to
which
the
stress
factor
can
be
applied,
and
these
effects
were
summed
to
determine
the cumulative impact of a factor on total assets, net assets and unitary net asset value.
The
results
of
the
stress
tests
were
presented
to
the
management
structures
and
will
be
taken
into
account
when
establishing
the
coordinates
of
the
investment/disinvestment
program
related
to
the
financial
year
2022,
when
implementing the Investment Strategy and for the synchronization of investments.
The
internal
audit
function
at
Transilvania
Investments
is
separate
and
independent
from
other
functions
and
activities
of
the company, and subordinated to the Supervisory Board.
In 2021, the internal audit function was exercised by Mazars Romania S.R.L.
The
internal
audit
missions
included
in
the
Internal
Audit
Plan
for
2021
were
carried
out
according
to
the
theme
endorsed
by
the
Audit
Committee
and
approved
by
the
Supervisory
Board
and
focused
on
the
activities
carried
out
by
the
compliance
office
(organization
and
development
of
compliance,
monitoring,
review
and
updating
of
existing
policies
and
procedures,
at
company
level,
F.S.A.
reports),
the
legal
department
(litigation
management,
consulting
the
Executive
Board,
organizing
meetings
of
the
Executive
Board,),
human
resources
activity
(calculation
of
salaries,
contributions
and
taxes,
recruitment
and
management
of
staff,
evaluation,
promotion
and
bonuses
of
employees),
information
technology
(equipment
security,
access control, information security incident management, business continuity plan).
The
internal
audit
activity,
carried
out
throughout
2021,
was
verified
by
the
Audit
Committee,
which
found
no
irregularities
or
inaccuracies
in
the
content
of
the
reports
submitted
to
the
Supervisory
Board
and,
consequently,
the
manner
in
which
the internal audit missions were carried out was validated.
Please
note
that
the
Ordinary
General
Meeting
of
Shareholders
of
28
April
2021
approved
the
appointment
of
Mazars
Romania
S.R.L.
Bucharest
as
financial
auditor
of
Transilvania
Investments
for
a
term
of
3
years,
respectively
from
1
January
2022 to 31 December 2024, for auditing the financial statements related to the financial years 2022, 2023 and 2024.
7.10
Assessment of the company’s activity regarding the risk management
The
risk
management
activity
is
reflected
in
the
Company's
organizational
and
operational
structure
and
covers
both
general
risks
and
specific
risks,
as
provided
by
Law
no.
297/2004
on
the
capital
market
,
as
subsequently
amended
and
supplemented,
Law
no.
74/2015
on
alternative
investment
fund
managers
,
N.S.C.
Regulation
no.
15/2004
regarding
the
authorization
and
operation
of
the
investment
management
companies,
collective
investment
bodies
and
depositories
,
as
subsequently
amended
and
supplemented,
F.S.A.
Regulation
no.
9/2014
on
the
authorisation
and
operation
of
Investment
Management
Companies
,
Undertakings
for
Collective
Investment
in
Transferable
Securities
and
of
the
Depositaries
of
Undertakings
for
Collective
Investment
in
Transferable
Securities
,
amended
and
supplemented
under
Regulation
no.
2/2018,
F.S.A.
Regulation
no.
10/2015
regarding
the
management
of
the
alternative
investment
funds
,
F.S.A.
Rule
no.
4/2018
regarding
the
management
of
operational
risks
generated
by
computer
systems
used
by
entities
authorized/endorsed/registered
and/or
supervised
by
the
Financial
Supervisory
Authority
,
Law
no.
243/2019
on
the
regulation of alternative investment funds, as well as amending and supplementing regulations.
